... CJ said in Dyson1: - "The proper question to have been submitted to the jury was whether the prisoner accelerated the child's death by the injuries which he inflicted in December, 1907. For if he did, the fact that the child was already suffering from meningitis, from which it would in any event have died before long, would afford no answer to the charge of causing its death." Causation is in some sense a difficult area of the law. As The Criminal Law and Penal Reform Committee in south Australia stated2: - "There is no more intractable problem in the law, than causation." Causation can be split into two parts, factual causation and legal causation. The issue of factual causation is generally one for jury to decide. However, when answering the question, they must apply the legal principles that the judge has explained to them. As Lord Salmon said in Alphacell Ltd ...

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